DEPUTY GENERAL MANAGER — THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

DEPUTY GENERAL MANAGER ALTERNATIVE INVESTMENT FUND AND FOREIGN PORTFOLIO INVESTOR DEPARTMENT DIVISION OF POLICY AND DEVELOPMENT -I Ms. Dimple Mirchandani , Firstport Ventures LLP, Investment Manager of FirstPort Capital Angel Fund , 239, 2 nd floor, Tower A, JMD Megapolis, Sector 48, Gurugram, Haryana 122018. Madam , Sub: Request for Informal Guidance by way of interpretive letter under the provisions of the Securities and Exchange Board of India (Informal Guidance) Scheme, 2003 in connection with provisions for Angel funds under the Securities and Exchange Board of India (Alternative Investment Funds) Regulations, 2012 Ref: Your letter dated April 12, 2024 and subsequent correspondences on the letter In your letter / communications under reference, you have, inter-alia, stated that FirstPort Capital Angel Fund ("Fund") is registered with SEBI as a Category I – Venture Capital Fund – Angel Fund and that you have come across certain operational issues while operating as an Angel Fund, on which guidance is required . In this context, you have sought an interpretive letter under the Securities and Exchange Board of India (Informal Guidance) Scheme 2003 ('Informal Guidance Scheme') from SEBI on the following queries - Query I: Angel Fund had made an investment in a start-up, meeting eligibility criteria as per DPIIT notification (G.S.R 34 (E) dated January 16, 2019). Subsequent to this investment, the start-up ("Investee Company") over a period of time ceases to be eligible as a start-up under the eligibility criteria as per DPIIT notification. In such an event, whether the Fund can exercise its pre-emptive right/rights issue/Renounced rights issue of shares against convertible securities as per SEBI/HO/AFD/PoD-1/OW/2025/7738 March 13, 2025 Shareholders Agreement by subscri